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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

47) ll-C-73 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:28 PM Sheet 47 of 343 
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A-94-52 

$ -t% \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| ^ff2. i RESEARCH TRIANGLE PARK, NC 27711 

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\ PRO^° 

OFFICE OF 

CfTQ O n lOO?

 A, R QUAl-ITY PLANNING 

OC OU iyy/ ANOSTANOARDS 

Mr. Bob Lacovara, Technical Director 

Composites Fabricators Association 

39 BCingerman Road 

Telford, Pennsylvania 18969 

Dear Bob: 

Per our conversation on September 23, 1997, there are several items that are needed for 

the Environmental Protection Agency (EPA) to better evaluate the Composites Fabricators 

Association (CFA) proposal for developing existing source maximum achievable control 

technology (MACT) floors for open molding. The two immediate needs I identified and we 

discussed over the phone are (1) development of a method for determining the effectiveness of 

vapor suppressed resins on a case-specific basis, and (2) emissions data comparing flow coaters 

and pressure fed rollers to spray application on the same resins and characteristics studied in the 

Phase I CFA testing. These immediate needs are briefly summarized below. 

A test method is needed to determine the effectiveness of vapor suppressed resins to aid 

facilities that choose to use suppressants to comply with the MACT standards. While data are 

available on some resin-suppressant mixes, there is no present method of determining the 

effectiveness of a particular suppressant when used with a particular resin mixture. The available 

data indicates that suppressants have different effectiveness when used with filled and unfilled 

resins, and there are potentially other suppressant/resin characteristics that could affect 

suppressant effectiveness on a case-specific basis. A laboratory type test method would be able 

to indicate the effectiveness of a particular suppressant on a particular resin mixture, which 

would be essential for utilizing the approach proposed by the CFA. Once the laboratory method 

is developed, we may then look at emission profiles to determine how the test method results 

could be applied to a particular operation to predict the effectiveness of the suppressant on a 

particular operation. As you mentioned on the phone, the EPA would be very interested in 

participating in the various development stages ofthe test method. 

The second need is additional data to develop a more accurate control factor for nonspray resin application. In the present CFA model, the emission reduction associated with nonspray resin application is constant and not a function of HAP content. From review of the test 

data from the National Marine Manufacturers Association and from logical considerations, it 

would appear that the emission reduction would depend on the styrene content 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Hecycled Paper (40% Postconsumer) 

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ofthe resin. By looking at the emission reduction for different gel times and thicknesses, we 

would be able to determine how these variables also affect the emission reduction and see how 

any potentid variability in emission reduction could be taken into account in the model. 

I appreciate our conversation on these information needs and your willingness to provide 

these. I believe the data gained from your efforts will help us work together to craft an approach 

that will meet both the EPA's and industry's goals. Please note that the EPA may have 

additional questions and request additional data as we further analyze the approach. I have 

requested these two immediate needs at the present time in order to expedite their development 

and speed our evaluation and consideration ofthe approach for use in the reinforced plastics 

MACT standard. 

Sincerely, 

^'kcLU*u^ 

Madeleine Strum 

Environmental Engineer 

Coatings and Consumer Products Group 

cc: Mr. Steve McN«ally, Composite Fabricators Association 

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